The Foreign Corrupt Practices Act (FCPA) makes it a crime for “any officer, director, employee, or agent” of an issuer of U.S. securities “to make use of the mails or any means or instrumentality of interstate commerce” in furtherance of any corrupt offer, promise or payment to a foreign official.

As a child, Joe Brennan dreamed of becoming a marine biologist, but when a post-college stint as a paralegal at Mayer Brown instead convinced him to attend law school, it appeared that his love of science would remain a personal interest, not a professional calling.